Latin Am. Music Co., Inc. v. Media Power Group, Inc., No. 11-2108 (1st Cir. 2013)Annotate this Case
Media Power Group, Inc. (MPG) owned four radio stations in Puerto Rico, branded "Radio Isla." Segments of several disputed songs were broadcast during various news and talk show programs on Radio Isla. Latin American Music Company (LAMCO) filed suit against MPG and its president, seeking money damages for violations of the Copyright Act as to twenty-one songs. The district court granted MPG's motion for summary judgment as to twelve songs, and infringement claims as to the remaining nine songs were tried before a jury. The jury found LAMCO failed to prove it owned the songs and returned a verdict for MPG. The First Circuit Court of Appeals affirmed, holding (1) the issue of ownership was properly submitted to the jury; (2) the district court did not err when it ruled that LAMCO was collaterally estopped from litigating its claims as to four songs; and (3) the district court did not err in dismissing LAMCO's claims relating to four other songs for failure to produce evidence of registration.